HMRC successfully applied for the appellants’ tax appeals to be struck out due to non-compliance with directions issued by the tribunal.
The appellants participated in a tax avoidance scheme. They appealed against closure notices issued by HM Revenue and Customs (HMRC) under TMA 1970, s 28. HMRC applied for directions in relation to the appellants’ appeals. The application included a request for a direction that the appellants provide further and better particulars of their cases. The First-tier Tribunal (FTT) granted HMRC’s application, and set a deadline for the appellants to comply.
The appellants subsequently requested extensions of time limits to serve the replies. On 18 February 2016, the FTT issued directions requiring the appellants to serve their replies by 3 March 2016, and made a ‘conditional unless order’ indicating that failure to comply with the directions may lead to the
